- 14 -
high. In N. Trust Co., we allowed a 25-percent minority discount
for a 25-percent voting interest in a corporation. In this case,
we hold that a 10-percent discount is applicable, but a holding
of a 6-percent discount is sufficient to sustain the adjustment
in the notice of deficiency. Therefore, we sustain respondent’s
adjustment without reaching the other arguments for discount
raised by respondent.
Conclusion
After applying a minority-position discount of 10 percent,
we would find that the 45-percent interest in Sealodge
transferred by Mr. Koblick had a value of $429,300 at the time of
his gift of stock to MRDF. Therefore, the deduction value would
be $429,300 less $90,000 or $339,300. Because the notice of
deficiency determines a higher value, we sustain that
determination and find that
Decision will be entered
for respondent.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
Last modified: May 25, 2011